Policy & Code of Practice

Policy and Code of Practice for the Prevention and Combating of Harassment and Sexual Harassment

Sexual harassment is a social phenomenon and constitutes a form of gender-based violence. This behaviour, which may manifest in various ways, aims at or results in the violation of a person’s dignity, particularly by creating an intimidating, hostile, degrading, humiliating, or offensive environment. At Global College, such conduct is met with zero tolerance. The College recognises that sexual harassment obstructs the implementation of equality in the fields of employment and education. Gender-based violence violates both the Law and the fundamental principles and values of the College.

The College Administration, in alignment with the Equal Treatment of Men and Women in Employment and Vocational Training Law of 2002 to 2021, has developed the “Code of Practice for the Prevention and Combating of Harassment and Sexual Harassment” with the purpose of preventing and addressing incidents of harassment and sexual harassment within the Academic Community of the College. The College, acknowledging the seriousness of the offence, deems any behaviour constituting harassment or sexual harassment unacceptable and is committed to maintaining an environment in which every individual’s dignity is fully protected and personal integrity is respected by all. Such behaviour constitutes both a disciplinary offence and a criminal act.

In addition, the Code of Practice establishes and implements an internal procedure for handling and investigating complaints with full confidentiality.

Aims of the Code of Practice

The Code of Practice aims to prevent and address harassment and sexual harassment, and specifically:

To inform employees of the College about the concepts of “harassment” and “sexual harassment,” the protection provided by applicable legislation against such behaviours, their rights if they experience such conduct, and the actions they should take if they believe they are victims of harassment or sexual harassment.
To promote education and training for employees on the importance of:
(a) the principle of equal treatment between men and women,
(b) the prohibition of discrimination based on gender or sexual orientation, and
(c) the prevention, management, and combating of harassment or sexual harassment.
To encourage employees to participate in and contribute to the prevention and management of harassment and sexual harassment in the workplace and to the creation of a friendly work environment for all, regardless of gender or sexual orientation.
To encourage every competent authority to adopt and implement a policy to prevent harassment and sexual harassment in the workplace, and to establish a mechanism for monitoring and evaluating its effectiveness with a view to improving it.
To promote cooperation between competent authorities and employees in maintaining a healthy and safe working environment characterised by mutual respect, politeness, honesty, understanding, and support.
To provide immediate protection to any employee who believes they are being or have been subjected to harassment or sexual harassment, as well as from any retaliatory actions for rejecting such behaviour or for lodging a complaint.
To define the obligations of competent authorities in cases where they suspect, become aware of, or receive a complaint about an incident of harassment or sexual harassment.
To guide competent authorities on the proper and prompt handling of complaints and the protection of victims and other parties involved in the complaint investigation.

Policy Statement

As a first step in expressing its commitment to combating sexual harassment and harassment, the College issues the following policy statement:

Discrimination based on gender, harassment, and sexual harassment are strictly prohibited.
All members of the Academic Community of the College have a duty to comply with and support the College’s policy and the provisions contained in this Code of Practice.
All members of the Academic Community of the College have an obligation to maintain strict confidentiality when providing information as part of a complaint investigation. The discussion of confidential information or the spreading of rumours will not be tolerated.
All members of the Academic Community of the College, as well as job applicants and other individuals cooperating with the College, have the right to be treated with equality and dignity.
Harassment and sexual harassment in the workplace shall not be tolerated or accepted. The College shall take all appropriate measures to this end, as provided by relevant legislation and this Code of Practice.
Complaints regarding harassment or sexual harassment shall be handled promptly, seriously, and with full confidentiality.
All members of the Academic Community of the College shall be protected against victimisation, adverse treatment, or detrimental changes to their conditions as a result of their involvement in any way (e.g., complaint, testimony) in the investigation of a harassment or sexual harassment complaint.

This Code of Practice is communicated to the entire Academic Community of the College and is published on the College’s website.

Scope of the Code of Practice

This Code of Practice applies to all individuals who are part of the Academic Community of the College. Specifically, it includes:

Members of the Academic Staff employed under any employment status (Full-Time Faculty, Part-Time Faculty, and Special Teaching Personnel)
Members of the Administrative Staff employed under any employment status
Students
Other individuals who have dealings with or collaborate with the College.

Useful Terms and Definitions

Unwanted Behavior refers to any conduct that is unpleasant and offensive to an individual. It does not matter whether the behavior is isolated or repeated. It is also irrelevant how the perpetrator perceives their own behavior toward the recipient, or what the perpetrator’s intent was. The recipient is not required to inform the perpetrator that the behavior is unwanted.

The fact that the behavior may be deemed acceptable by others, or may have been considered acceptable in the past within the work environment, does not negate its classification as unwanted behavior as defined above.

Competent Authority, for the purposes of this Code of Practice, refers to those individuals responsible for handling complaints or reports of harassment or sexual harassment, as well as for taking preventive and corrective measures. It is the responsibility of these authorities to be adequately trained in the prevention and management of harassment and sexual harassment cases.

At the College, the Competent Authorities include:

The College Council
Heads of Academic Departments
Programme Directors
Members of the Disciplinary Committee, Academic Committee, and Human Resources Office
Financial Director
Head Librarian
Department Supervisors

All of the above must adhere to and implement this Code of Practice and specifically:

The College Council, Heads of Academic Departments, Programme Directors, Supervisors, students, and employees must refrain from any acts of harassment or sexual harassment.
All of the above play a role in helping to create and maintain an environment (for staff and students) where harassment and sexual harassment are unacceptable. They must ensure that their own conduct does not cause harm and must discourage unacceptable behavior by others.
The College Council, Heads of Academic Departments, Programme Directors, and Department Supervisors must take the necessary measures as required by the Code when cases of harassment or sexual harassment occurring in their areas of responsibility come to their attention.

Sex-Based Discrimination means any direct or indirect discrimination, including sexual harassment or less favorable treatment as a result of rejecting or submitting to such conduct. It also includes less favorable treatment of a woman related to pregnancy, childbirth, breastfeeding, maternity, or illness related to pregnancy or childbirth. Any instruction or command to discriminate based on sex also constitutes discrimination.
Harassment is any unwanted behavior from the perspective of the recipient, related to their sex or sexual orientation, which has the purpose or effect of violating their dignity, particularly when it creates an intimidating, hostile, degrading, humiliating, or offensive environment.
Sexual Harassment refers to any unwanted behavior of a sexual nature from the perspective of the recipient, which has the purpose or effect of violating their dignity, especially when it creates a humiliating, intimidating, hostile, degrading, or offensive environment in employment, professional education or training, or access thereto. It may be expressed through words or actions.

The defining elements of “harassment” and “sexual harassment” include:

Unwanted behavior
Behavior based on sex (for harassment) or of a sexual nature (for sexual harassment)
Conduct that may reasonably be considered, under the circumstances, as offensive, intimidating, and degrading by the recipient and that creates a hostile work environment

Sexual Behavior includes any conduct with a sexual element, tone, or implication, expressed through words or actions. Examples (non-exhaustive) include:

Behavior expressed through actions: Unwanted physical contact aimed at coercion or sexual advances
Behavior expressed through words: Unnecessary or unwanted familiarity, sexual or offensive remarks, jokes, comments on sex or sexual orientation, discussions with sexual content, sexual propositions or pressure, intrusive questions about one’s private life, sexually suggestive or obscene language, inappropriate compliments or flirting
Non-verbal behavior: Display of pornographic material, obscene images or objects, whistles, suggestive stares or gestures, unwanted proximity, sexually offensive texts or messages via mobile or digital platforms
Sexual Harassment from a Position of Authority: When a supervisor, manager, or lecturer attempts to influence employment conditions, promotions, training, salary increases, or student academic standing in exchange for sexual favors.
Sexual Favoritism: When a person in a position of power rewards those who comply with sexual requests while penalizing those who do not (despite being equally or more qualified).

The perpetrator’s intent, whatever it may be, is irrelevant and unacceptable. Even a single incident may constitute sexual harassment. Different individuals may react differently to the same behavior, but this does not justify or excuse the perpetrator’s actions, nor does it lessen the responsibility of the competent authority. What matters is whether the behavior was reasonably perceived as offensive, unwanted, or intimidating by the recipient.

Forms of Sexual Harassment and Harassment

Sexual behavior that is considered unpleasant, offensive, intimidating, degrading, or aggressive by the recipient may be expressed in the following ways:

Verbal behavior:
Unnecessary familiarity, sexual comments, jokes, anecdotes and gestures, derogatory or sexist language, immoral or offensive remarks about gender or sexual orientation, steering conversations toward sexual topics, describing sexual experiences in front of others, unwanted suggestions or advice, intrusive questions about personal or sexual life, sexual innuendos, insults, invitations for dates or sexual encounters, confessions, flirtatious or sexually charged compliments.
Non-verbal behavior:
Persistent or lascivious staring, suggestive glances, unwanted touching of clothing, hair, or body parts, pinching, caressing, kissing, whistling, unnecessary closeness or proximity, sexually suggestive gestures or movements.
Invasion of personal life:
Attempts to distribute sexual material, such as images, magazines, or videos.
Other types of conduct:
Written or verbal flirting, letters or messages with sexual content, suggestive phone calls or electronic communications (texts, emails), displaying sexual images or posters.
Sexual harassment as quid pro quo:
Forcing someone into a sexual relationship in exchange for employment, promotion, salary increase, or threatening demotion or dismissal if the sexual request is denied.
Hostile environment:
Unreasonable interference with a person’s work performance and creation or exposure of the victim to a hostile, uncomfortable, or offensive environment.

The behaviors and actions listed above are indicative and not exhaustive.

Sexual harassment and harassment due to gender or sexual orientation may manifest in various forms.

Indicative Examples of Sexual Harassment

The following are indicative (but not exhaustive) examples of conduct that may constitute sexual harassment:

Offensive or unnecessary touching and fondling of any part of the body
Gestures with any part of the body or signals with the eyes, mouth, etc.
Immoral or offensive sexual suggestions
Remarks about motherhood and its associated benefits (e.g., leaves, accommodations)
Comments or characterizations concerning marital status, dress code, or appearance
Remarks about someone’s body, face, sexual orientation, sexual performance, or sexual deficiencies
Innuendos that offend sexual dignity
Written or verbal insults of a sexual nature
Written or verbal sexually suggestive comments or flirtatious messages
Display or exposure of sexual images, photographs, films, or messages by any means or medium, including electronic (e.g., emails, SMS, etc.) or non-electronic
Requests or demands for sexual favors, especially with the promise of employment, promotion, protection from dismissal, etc.
Remarks containing sexual innuendos
Derogatory remarks about someone’s gender or appearance
Questions about sexual behavior or narration of sexual experiences to the victim
Invasion of privacy, inside or outside the workplace (e.g., harassing phone calls)
Sexual assault and coercion into sexual acts
Sexual jokes or teasing
Repeated invitations to dinner or outings despite their rejection by the victim

However, it should be noted that it is normal and expected in a modern workplace, where employees spend much of their day, to engage in social activities beyond work. Indeed, many couples have met in the workplace. The same may apply among students.

What must be emphasized, however, is the unwelcome nature of the behavior.

None of the above behaviors constitutes sexual harassment if it is not unwelcomed by the recipient or if it is not of a nature or degree that offends the dignity of men and women. If the behavior is mutually acceptable and consensual, then it does not fall under the scope of sexual harassment.

It is clear that the intent (good or bad, innocent or guilty, aware or unaware) of the perpetrator is completely irrelevant and has no bearing. A good intention does not negate behavior that constitutes sexual harassment.

Guidelines for All Members of the College Academic Community on Preventing and Addressing Harassment and Sexual Harassment

Guidelines for Preventing Harassment and Sexual Harassment

Seek comprehensive and objective information on the legislation related to harassment and sexual harassment and on available protection mechanisms.
Participate in activities and programs aimed at combating gender-based discrimination, stereotypes, and prejudices that perpetuate harassment and sexual harassment.
Avoid discussions, comments, insinuations, gestures, or expressions that target or reference an individual’s gender, sexual orientation, or gender identity.
Adjust your behavior when you realize it offends or upsets someone, and do not hesitate to apologize.
Clearly set personal boundaries when you detect behavior that bothers or offends you.
Cooperate with the competent authority to improve the working/academic environment and to support the implementation of the Code of Practice.

Guidelines for Addressing Harassment and Sexual Harassment

Victims of harassment or sexual harassment often try to ignore or hide the incident. Avoid this defensive, tolerant, harmful, and unproductive approach, and instead:

Do not ignore or underestimate the discomfort or negative feelings caused by the behavior.
Trust your judgment about the person’s behavior.
Do not feel embarrassed, ashamed, or blame yourself for the perpetrator’s behavior (whether male or female).
Do not isolate yourself from others.
Do not justify the behavior of the perpetrator (whether male or female).

Take responsibility to act appropriately:

Set clear boundaries with the perpetrator (male or female).
Reject or calmly and firmly confront their behavior.
If the individual continues the harassment or sexual harassment despite your efforts, confide in someone you trust and inform your family as well.
Keep a diary recording the incidents of harassment or sexual harassment.
Inform the competent authority.
Submit a written complaint to the competent authority or a report to the appropriate institutional body, clearly and objectively stating what occurred, when, and where.
Consult the Commissioner for Administration and the Protection of Human Rights (Ombudsman) as the Equality Body and Anti-Discrimination Authority, or the Gender Equality Committee in Employment and Vocational Education, or Labor Department Inspectors of the Ministry of Labor, Welfare and Social Insurance.

Duties and Responsibilities of the College Administration

Ensuring a Dignified Work Environment

The College Administration:

Recognizes that harassment and sexual harassment are forms of gender-based violence and constitute prohibited discrimination based on sex in the workplace.
Has a legal obligation to ensure a safe, dignified, healthy, and friendly work environment.
Holds responsibility for the prevention and management of harassment and sexual harassment.

Specifically, the College Administration:

Protects employees and students of the College from any act constituting sex-based discrimination, especially behavior that amounts to harassment or sexual harassment, as well as any act of direct or indirect adverse treatment resulting from rejection of harassment or sexual harassment or from the submission of a related complaint/testimony.
Has an obligation toward the employee or student who has experienced harassment or sexual harassment, and/or adverse treatment due to rejecting such behavior or filing a related complaint. As soon as the specific behavior or its consequences come to the Administration’s attention, it must take all appropriate measures to stop and prevent its recurrence, as well as to address its consequences.

Failure to act renders the competent authority jointly responsible with the person who committed the reported prohibited acts.

Measures Taken by the College Administration to Prevent Harassment and Sexual Harassment

The College Administration communicates the Code of Practice to all staff and students, in writing or through other means, and ensures that sexual harassment in the workplace or academic environment is not tolerated, taking appropriate measures in cases of non-compliance.
Ensures a working environment that is accessible, safe, and friendly, where relationships among employees and among members of the Academic Community are characterized by mutual respect, politeness, honesty, understanding, trust, cooperation, and support.
Provides education and training programs for members of the Academic Community concerning prohibited forms of discrimination, the importance of combating and eliminating them, and the stereotypes that sustain and reproduce discrimination, gender-based violence, sexual harassment, and inequality in employment. These programs also cover relevant legislation and the benefits of compliance.
Establishes a Gender Equality Committee responsible for monitoring the implementation of the Code of Practice, assessing its effectiveness, and submitting recommendations to any competent authority regarding necessary improvements and organizing the above-mentioned training programs. The Gender Equality Committee must also organize periodic awareness seminars and disseminate informational material to the College community and foster collaboration with related internal committees and external bodies.
Encourages members of the Academic Community to cooperate with the Gender Equality Committee, contribute to its activities, and express their views on prevention and anti-harassment measures and their effectiveness in relation to the working environment.

Submission and Examination of Complaints

The College has established clear procedures for addressing harassment and sexual harassment. These procedures aim to resolve issues promptly and effectively. Resolution may follow either an informal or a formal process.

Internal/Informal Procedure

The internal procedure is intended to investigate and address incidents within the College:

The complainant addresses the College Administration and submits their complaint in writing.
The College Administration records the incident’s history and explores the possibility of immediate communication or mediation.
Depending on the circumstances, and with the complainant’s written consent, the College Administration either:
(a) encourages the complainant to explain to the person causing the unwanted behavior that it is unwelcome, offensive, distressing, and interferes with their work/studies, or
(b) undertakes mediation.
The College Administration takes action only if the harassment or sexual harassment occurred over a short period, the alleged perpetrator appears willing to discuss the matter, and the complainant agrees to mediation.
If the complainant opts to speak directly to the alleged perpetrator, the College Administration is responsible for monitoring the outcome.
In the case of mediation, the College Administration initiates contact with the alleged perpetrator.
In all cases, the College Administration handles the situation with full confidentiality and ensures that it is resolved within a reasonable timeframe.

The College Administration ensures that the internal/informal complaint examination procedure:

Is clear, explained, and understood by all members of the College community.
Is conducted with confidentiality and impartiality.
Offers adequate guidance and support to the complainant.
Treats both the complainant and the respondent with respect.
Ensures that neither party is victimized.
Protects any potential witnesses from victimization.
Produces results within a reasonable timeframe from the date of submission.
Encourages the complainant to report harassment or sexual harassment incidents either orally or in writing.
Advises the complainant to carefully preserve any relevant evidence concerning the behavior of the respondent.
Asks whether the complainant wishes to address the issue personally or needs assistance.
Informs the complainant of their right to file a formal complaint.
Where necessary, and without stigmatizing the parties involved, professional contact is avoided or individuals are relocated if they share close physical workspaces.

The informal procedure does not involve a formal complaint. It constitutes a preliminary grievance and does not replace the formal procedure for reporting and investigating harassment or sexual harassment. The complainant may, at any stage, switch to the formal procedure or file a complaint with state authorities or take legal action.

Internal/Formal Procedure

To initiate the formal complaint process for sexual harassment or harassment, the complainant must submit a written report to the appropriate body or disciplinary committee.

The complaint will be investigated according to the procedures established by the College’s disciplinary regulations and internal rules, depending on whether the respondent is a member of the academic staff, administrative staff, or a student.

It is understood that, in any case, harassment or sexual harassment may also be reported to the Police, which will investigate the matter as a potential criminal offense.

Criminal and Civil Procedures

A victim of sexual abuse has the right to initiate separate criminal or civil proceedings against the alleged perpetrator. The victim’s legal rights are in no way restricted or affected by the College’s disciplinary rules, internal regulations, or this policy.

State Institutions and Other Bodies for Submitting Complaints

A complaint or report of harassment or sexual harassment can also be submitted to the following institutions:

Commissioner for Administration and the Protection of Human Rights (Ombudsman) – Equality Body and Anti-Discrimination Body
Address: Era House, 2 Diagorou Street, 1097 Nicosia
Tel: 22405500 / 501
Website: www.ombudsman.gov.cy
Email: ombudsman@ombudsman.gov.cy
Gender Equality Committee in Employment and Vocational Training
Address: 9 Klementos Street, 3rd floor, Office 312, Nicosia
Tel: 22400894 / 5
Website: www.eif.gov.cy
Email: genderequalitycommittee@mlsi.gov.cy
Labour Department Inspectors, Ministry of Labour, Welfare and Social Insurance
Address: 9 Klementos Street, 4th floor, Nicosia
Tel: 22400801
Email: director@dl.mlsi.gov.cy